FHLMC Guide Bulletin 2013-21 Updates Mortgage Servicing Requirements

On October 11, Freddie Mac released Guide Bulletin 2013-21, subtitled Updates in Response to the CFPB Mortgage Servicing Final Rule.


Freddie Mac is providing Servicers with updated mortgage servicing requirements in today’s Single-Family Seller/Servicer Guide (Guide) Bulletin 2013-21. The updated requirements are in response to the Consumer Financial Protection Bureau’s (CFPB) final rule, which implements the mortgage servicing provisions of the Truth-in-Lending Act and Real Estate Settlement Procedures Act, as amended by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

All of the changes announced in this Guide Bulletin are effective for Servicing activities completed on or after January 10, 2014.

The revised requirements announced in today’s Guide Bulletin, which impact requirements adopted under the Federal Housing Finance Agency (FHFA)-directed Servicing Alignment Initiative, are the result of discussions between Freddie Mac, Fannie Mae, and FHFA to assess the implications of the final rule. FHFA has directed us to align with Fannie Mae on the revised requirements included in this Guide Bulletin.

Servicers Are Responsible for CFPB Final Rule Compliance

While Freddie Mac has established our servicing requirements in response to the CFPB’s final rule, Freddie Mac will not interpret CFPB regulations for Servicers or determine how Servicers should comply. Compliance with the CFPB final rule and other applicable laws are the Servicer’s responsibility. A Servicer’s compliance with Freddie Mac’s requirements does not ensure that the Servicer is in compliance with the CFPB final rule or any other applicable laws.

Servicing Requirements for Delinquent Mortgages Secured by Primary Residences

We’ve added new Guide Chapter 63, Delinquency Management on Mortgages Secured by Primary Residences, to provide guidance on communication and collection efforts, the appeals process, and foreclosure referrals and suspension. Please familiarize yourself with the following changes:

  • Collection Efforts and Use of a Loss Mitigation Tool. Servicers are prohibited from using a loss mitigation tool for purposes of delaying the initial borrower solicitation package required to be sent by the 35th day of delinquency. Servicers are now required to send the initial borrower solicitation package as early as the 31st day and no later than the 35th day of delinquency unless quality right party contact and borrower commitment to cure the delinquency has been obtained. Servicers may continue to use a loss mitigation tool to manage calling campaigns.
  • The Appeals Process. New requirements are being introduced for the borrower’s appeals process for the First Complete Borrower Response Packages (BRP) submitted 90 or more days prior to a foreclosure sale date or when a foreclosure sale date has not yet been scheduled. Refer to Guide Section 63.3 for these new requirements, the Guide Glossary for the newly defined “First Complete Borrower Response Package”, and Guide Exhibit 93, Evaluation Model Clauses, for updated evaluation model clauses.
  • Revised Foreclosure Referral Requirements. Servicers may no longer refer to foreclosure any earlier than the 121st day of delinquency unless one of the exceptions outlined in Guide Section 66.9.1 applies or applicable law permits earlier referral. Servicers must refer all mortgages secured by Primary Residences with expired breach letters to foreclosure no earlier than the 121st day of delinquency and no later than five business days after the 121st day of delinquency. In addition, Servicers must take the first legal action after referral to foreclosure.
  • Foreclosure Suspension Obligations. After referral to foreclosure, if a Servicer receives the First Complete BRP on a mortgage secured by a Primary Residence more than 37 days prior to a foreclosure sale date or a foreclosure date being scheduled, the Servicer must delay taking the first legal action. If the first legal action has been taken, Servicers must delay motion for judgment or order of sale unless certain conditions apply.

Servicing Requirements for All Mortgages

Today’s Guide Bulletin also announces updates for servicing requirements related to BRP acknowledgement, error resolution, disaster forbearance plans, and pre-referral to foreclosure.

  • BRP Acknowledgement. Within five business days of BRP receipt, Servicers must confirm in writing to borrowers that they’ve received the BRP.
  • Error Resolution. Freddie Mac has replaced our current case escalation requirements with provisions for error resolution for any servicing errors asserted by borrowers.
  • Disaster Forbearance Plan. A complete BRP must be obtained when the borrower is being considered for and offered a forbearance plan exceeding six months in length. In cases where borrowers impacted by an Eligible Disaster are unable to provide complete BRPs at the end of an initial six months of disaster forbearance, Servicers may offer a successive disaster forbearance plan up to an additional six months in length without a complete BRP. Servicers may not exceed a total of 12 months of disaster forbearance in total without Freddie Mac approval.
  • Pre-Referral to Foreclosure. Servicers now have up to 15 days to complete their pre-referral review prior to foreclosure referral. We’ve also eliminated the requirement for Servicers to postpone foreclosure referral for up to 10 days if a complete BRP is received.

Today’s Guide Bulletin has detailed information about these changes.

Reminder about CFPB and ECOA Final Rule

Finally, we’d like to remind Servicers to review Freddie Mac updated guidance related to the CFPB final rule that implements the Equal Credit Opportunity Act property valuation notice and disclosure requirements in our October 8 Guide Bulletin 2013-20.

Training and Resources

To help Servicers understand the new and revised requirements announced in this Guide Bulletin, we encourage registration for the Bulletins 2013-20 & 2013-21:  Servicing Updates in Response to the CFPB’s Mortgage Servicing Rules webinar.

Visit Freddie Mac’s Learning Center to view updated training materials supporting the changes announced in this Bulletin.

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About Safeguard 
Safeguard Properties is the largest mortgage field services company in the U.S. Founded in 1990 by Robert Klein and based in Valley View, Ohio, the company inspects and maintains defaulted and foreclosed properties for mortgage servicers, lenders,  and other financial institutions. Safeguard employs approximately 1,700 people, in addition to a network of thousands of contractors nationally. Website: www.safeguardproperties.com.



Alan Jaffa

Alan Jaffa is the chief executive officer for Safeguard, steering the company as the mortgage field services industry leader. He also serves on the board of advisors for SCG Partners, a middle-market private equity fund focused on diversifying and expanding Safeguard Properties’ business model into complimentary markets.

Alan joined Safeguard in 1995, learning the business from the ground up. He was promoted to chief operating officer in 2002, and was named CEO in May 2010. His hands-on experience has given him unique insights as a leader to innovate, improve and strengthen Safeguard’s processes to assure that the company adheres to the highest standards of quality and customer service.

Under Alan’s leadership, Safeguard has grown significantly with strategies that have included new and expanded services, technology investments that deliver higher quality and greater efficiency to clients, and strategic acquisitions. He takes a team approach to process improvement, involving staff at all levels of the organization to address issues, brainstorm solutions, and identify new and better ways to serve clients.

In 2008, Alan was recognized by Crain’s Cleveland Business in its annual “40-Under-40” profile of young leaders. He also was named a NEO Ernst & Young Entrepreneur of the Year® finalist in 2013.


Chief Operating Officer

Michael Greenbaum

Michael Greenbaum is the chief operating officer for Safeguard. Mike has been instrumental in aligning operations to become more efficient, effective, and compliant with our ever-changing industry requirements. Mike has a proven track record of excellence, partnership and collaboration at Safeguard. Under Mike’s leadership, all operational departments of Safeguard have reviewed, updated and enhanced their business processes to maximize efficiency and improve quality control.

Mike joined Safeguard in July 2010 as vice president of REO and has continued to take on additional duties and responsibilities within the organization, including the role of vice president of operations in 2013 and then COO in 2015.

Mike built his business career in supply-chain management, operations, finance and marketing. He has held senior management and executive positions with Erico, a manufacturing company in Solon, Ohio; Accel, Inc., a packaging company in Lewis Center, Ohio; and McMaster-Carr, an industrial supply company in Aurora, Ohio.

Before entering the business world, Mike served in the U.S. Army, Ordinance Branch, and specialized in supply chain management. He is a distinguished graduate of West Point (U.S. Military Academy), where he majored in quantitative economics.



Sean Reddington

Sean Reddington is the new Chief Information Officer for Safeguard Properties LLC. Sean has over 15+ years of experience in Information Services Management with a strong focus on Product and Application Management. Sean is responsible for Safeguard’s technological direction, including planning, implementation and maintaining all operational systems

Sean has a proven record of accomplishment for increasing operational efficiencies, improving customer service levels, and implementing and maintaining IT initiatives to support successful business processes.  He has provided the vision and dedicated leadership for key technologies for Fortune 100 companies, and nationally recognized consulting firms including enterprise system architecture, security, desktop and database management systems. Sean possesses strong functional and system knowledge of information security, systems and software, contracts management, budgeting, human resources and legal and related regulatory compliance.

Sean joined Safeguard Properties LLC from RenPSG Inc. which is a nationally leading Philintropic Software Platform in the Fintech space. He oversaw the organization’s technological direction including planning, implementing and maintaining the best practices that align with all corporate functions. He also provided day-to-day technology operations, enterprise security, information risk and vulnerability management, audit and compliance, security awareness and training.

Prior to RenPSG, Sean worked for DMI Consulting as a Client Success Director where he guided the delivery in a multibillion-dollar Fortune 500 enterprise client account. He was responsible for all project deliveries in terms of quality, budget and timeliness and led the team to coordinate development and definition of project scope and limitations. Sean also worked for KPMG Consulting in their Microsoft Practice and Technicolor’s Ebusiness Division where he had responsibility for application development, maintenance, and support.

Sean is a graduate of Rutgers University with a Bachelor of Arts and received his Masters in International Business from Central Michigan University. He was also a commissioned officer in the United States Air Force prior to his career in the business world.


General Counsel and Executive Vice President

Linda Erkkila, Esq.

Linda Erkkila is the general counsel and executive vice president for Safeguard and oversees the legal, human resources, training, and compliance departments. Linda’s responsibilities cover regulatory issues that impact Safeguard’s operations, risk mitigation, enterprise strategic planning, human resources and training initiatives, compliance, litigation and claims management, and mergers, acquisition and joint ventures.

Linda assures that Safeguard’s strategic initiatives align with its resources, leverage opportunities across the company, and contemplate compliance mandates. Her practice spans over 20 years, and Linda’s experience covers regulatory disclosure, corporate governance compliance, risk assessment, executive compensation, litigation management, and merger and acquisition activity. Her experience at a former Fortune 500 financial institution during the subprime crisis helped develop Linda’s pro-active approach to change management during periods of heightened regulatory scrutiny.

Linda previously served as vice president and attorney for National City Corporation, as securities and corporate governance counsel for Agilysys Inc., and as an associate at Thompson Hine LLP. She earned her JD at Cleveland-Marshall College of Law. Linda holds a degree in economics from Miami University and an MBA. In 2017, Linda was named as both a “Woman of Influence” by HousingWire and as a “Leading Lady” by MReport.


Chief Financial Officer

Joe Iafigliola

Joe Iafigliola is the Chief Financial Officer for Safeguard. Joe is responsible for the Control, Quality Assurance, Business Development, Accounting & Information Security departments, and is a Managing Director of SCG Partners, a middle-market private equity fund focused on diversifying and expanding Safeguard Properties’ business model into complimentary markets.

Joe has been in a wide variety of roles in finance, supply chain management, information systems development, and sales and marketing. His career includes senior positions with McMaster-Carr Supply Company, Newell/Rubbermaid, and Procter and Gamble.

Joe has an MBA from The Weatherhead School of Management at Case Western Reserve University, is a Certified Management Accountant (CMA), and holds a bachelor’s degree from The Ohio State University’s Honors Accounting program.


AVP, High Risk and Investor Compliance

Steve Meyer

Steve Meyer is the assistant vice president of high risk and investor compliance for Safeguard. In this role, Steve is responsible for managing our clients’ conveyance processes, Safeguard’s investor compliance team and developing our working relationships with cities and municipalities around the country. He also works directly with our clients in our many outreach efforts and he represents Safeguard at a number of industry conferences each year.

Steve joined Safeguard in 1998 as manager over the hazard claims team. He was instrumental in the development and creation of policies, procedures and operating protocol. Under Steve’s leadership, the department became one of the largest within Safeguard. In 2002, he assumed responsibility for the newly-formed high risk department, once again building its success. Steve was promoted to director over these two areas in 2007, and he was promoted to assistant vice president in 2012.

Prior to joining Safeguard, Steve spent 10 years within the insurance industry, holding a number of positions including multi-line property adjuster, branch claims supervisor, and multi-line and subrogation/litigation supervisor. Steve is a graduate of Grove City College.


AVP, Operations

Jennifer Jozity

Jennifer Jozity is the assistant vice president of operations, overseeing inspections, REO and property preservation for Safeguard. Jen ensures quality work is performed in the field and internally, to meet and exceed our clients’ expectations. Jen has demonstrated the ability to deliver consistent results in order audit and order management.  She will build upon these strengths in order to deliver this level of excellence in both REO and property preservation operations.

Jen joined Safeguard in 1997 and was promoted to director of inspections operations in 2009 and assistant vice president of inspections operations in 2012.

She graduated from Cleveland State University with a degree in business.


AVP, Finance

Jennifer Anspach

Jennifer Anspach is the assistant vice president of finance for Safeguard. She is responsible for the company’s national workforce of approximately 1,000 employees. She manages recruitment strategies, employee relations, training, personnel policies, retention, payroll and benefits programs. Additionally, Jennifer has oversight of the accounts receivable and loss functions formerly within the accounting department.

Jennifer joined the company in April 2009 as a manager of accounting and finance and a year later was promoted to director. She was named AVP of human capital in 2014. Prior to joining Safeguard, she held several management positions at OfficeMax and InkStop in both operations and finance.

Jennifer is a graduate of Youngstown State University. She was named a Crain’s Cleveland Business Archer Award finalist for HR Executive of the Year in 2017.


AVP, Application Architecture

Rick Moran

Rick Moran is the assistant vice president of application architecture for Safeguard. Rick is responsible for evolving the Safeguard IT systems. He leads the design of Safeguard’s enterprise application architecture. This includes Safeguard’s real-time integration with other systems, vendors and clients; the future upgrade roadmap for systems; and standards designed to meet availability, security, performance and goals.

Rick has been with Safeguard since 2011. During that time, he has led the system upgrades necessary to support Safeguard’s growth. In addition, Rick’s team has designed and implemented several innovative systems.

Prior to joining Safeguard, Rick was director of enterprise architecture at Revol Wireless, a privately held CDMA Wireless provider in Ohio and Indiana, and operated his own consulting firm providing services to the manufacturing, telecommunications, and energy sectors.


AVP, Technology Infrastructure and Cloud Services

Steve Machovina

Steve Machovina is the assistant vice president of technology infrastructure and cloud services for Safeguard. He is responsible for the overall management and design of Safeguard’s hybrid cloud infrastructure. He manages all technology engineering staff who support data centers, telecommunications, network, servers, storage, service monitoring, and disaster recovery.

Steve joined Safeguard in November 2013 as director of information technology operations.

Prior to joining Safeguard, Steve was vice president of information technology at Revol Wireless, a privately held wireless provider in Ohio and Indiana. He also held management positions with Northcoast PCS and Corecomm Communications, and spent nine years as a Coast Guard officer and pilot.

Steve holds a BBA in management information systems from Kent State University in Ohio and an MBA from Wayne State University in Michigan.


Assistant Vice president of Application Development

Steve Goberish

Steve Goberish, is the assistant vice president of application development for Safeguard. He is responsible for the maintenance and evolution of Safeguard’s vendor systems ensuring high-availability, security and scalability while advancing the vendor products’ capabilities and enhancing the vendor experience.

Prior to joining Safeguard, Steve was a senior technical architect and development manager at First American Title Insurance, a publicly held title insurance provider based in southern California, in addition to managing and developing applications in multiple sectors from insurance to VOIP.

Steve has a bachelor’s degree from Kent State University in Ohio.